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The Philippine Court of Tax Appeals issued a decision (CTA EB No. 2951) on Jan. 16, 2026 clarifying the treatment of unutilized input VAT refunds on zero‑rated export sales. The court partially granted a refund claim by a corporation engaged in export sales, after the Commissioner of Internal Revenue denied the request for lack of proof that service recipients were not doing business in the Philippines.
The Bombay High Court ruled that a minimum three‑month gap must exist between a Section 73(2) show‑cause notice and the final order under Section 73(10) in GST proceedings. Orders passed earlier, such as the two‑and‑a‑half‑month order in the A.M. Marketplaces case, were quashed. The decision underscores procedural fairness and the need for adequate time for taxpayers to respond.
Global e-Invoicing Requirements Tracker
On 21 January 2026 the Philippine Court of Tax Appeals issued CTA Case No. 10505, clarifying that unutilized input VAT refunds on zero‑rated sales must be substantiated with an administrative refund claim and proof of entitlement. The decision confirms that the Internal Revenue Commissioner’s denial of a 2018 excess input VAT refund was based on the taxpayer’s failure to meet these requirements.
The UK Supreme Court confirmed that VAT incurred on adviser fees related to an exempt share sale is not recoverable, applying a strict two‑stage test that requires a direct and immediate link to the transaction. The ruling rejects the modified approach that allowed recovery based on intended use of proceeds and clarifies that VAT grouping does not alter the nature of a share sale. Businesses must conduct early VAT analysis for share disposals to account for irrecoverable adviser fees.
The Philippine Court of Tax Appeals issued a decision on Jan. 19, 2026 (Case No. 10607) clarifying the validity of assessments for alleged tax deficiencies. The ruling covers a range of taxes—including income tax, VAT, expanded withholding tax, and others—and finds that due process was not violated because the Final Decision on the Disputed Assessment (FDDA) stated the relevant facts. The decision provides guidance on how assessments are evaluated for due process compliance.
The German Ministry of Finance clarified rules on input VAT deductions for subsidized service providers that operate at persistent loss. The BMF Letter states that such providers cannot deduct input VAT for services unrelated to taxable activity and must satisfy a two‑step test linking remuneration to performance and confirming economic activity. The letter also amends the VAT Application Decree.
The Philippine Court of Tax Appeals issued a decision on Jan. 16, 2026 in CTA Case No. 10570, ruling that yearbook printing is VAT‑exempt because yearbooks qualify as books under Philippine law. The ruling invalidated the Commissioner of Internal Revenue’s assessments for deficiency income tax and VAT for the taxable year 2013, which had been based on BIR Ruling No. 421‑2013. The decision clarifies the validity of such assessments and the treatment of yearbook sales for VAT purposes.
Zimbabwe’s tax authority has clarified that non‑resident digital service providers must remain VAT‑registered if their annual turnover from services consumed in Zimbabwe exceeds USD 25,000, even after the introduction of Digital Services Withholding Tax (DSWT). The DSWT withholding amount is credited against the supplier’s VAT liability, but all compliance obligations, including fiscalisation, continue to apply. The fiscalisation mandate has been live for all VAT‑registered taxpayers since June 2025.
HMRC has reset UK VAT grouping rules, allowing overseas establishments to be treated as part of a UK VAT group and removing EU case law such as Skandia and Danske Bank. The new policy reduces cross‑border VAT friction and invites businesses to correct over‑declared VAT, while expanding HMRC’s discretion to deny grouping where it sees collection risk or distortive outcomes.
The Canada Revenue Agency has reversed its long‑standing position, declaring that trailing commissions paid by fund managers to dealers are taxable under GST/HST, effective July 1. Dealers and advisors may need to register for GST/HST if their taxable revenues exceed $30,000 over four consecutive quarters, and will have to adjust accounting systems to collect and remit the tax. The CRA will publish a formal technical interpretation in the coming weeks, clarifying the taxable status of trailing commissions and confirming that upfront commissions remain exempt.
The Czech Tax Agency clarified its VAT rules for real estate effective July 1, 2025. The guidance redefines key concepts, expands exemptions for completed immovable property, introduces a new substantial‑change definition requiring costs above 30% of the tax base, and adds new classifications for residential and social housing. These changes align Czech VAT with EU case law and modify when and how VAT is applied to real‑estate transactions.
The Danish National Tax Court confirmed that extraordinary VAT reassessment is permissible when gross negligence is proven. In a case involving a Danish airline, the court upheld the tax authorities’ findings that the company used incorrect input VAT deduction percentages, failed mandatory year‑end adjustments, and understated its liability. The decision clarifies that repeated errors and prohibited energy‑tax deductions justify extraordinary reassessment.
The Nicaraguan Directorate General of Revenue issued Notice No. 010-01-2026 on Jan. 16, 2026, setting a Jan. 20 deadline for large taxpayers (GRACOS) to pay advance VAT for the first half of January. Failure to meet the deadline could impact tax solvency. This guidance applies to large taxpayers in Nicaragua.
The Slovak Financial Administration released Guide No. 1/DPH/2026/I on January 14, 2026, outlining amendments to the VAT Act. Key provisions include mandatory electronic invoicing for domestic supplies from 1 January 2027 to 30 June 2030 and an option for the tax office to require customers to pay VAT directly to the tax administrator’s account if a supplier is suspected of non‑payment. The guidance applies to all Slovak taxpayers engaged in domestic supply of goods and services.
On January 14, the Lithuanian State Tax Inspectorate released a summary explanation outlining VAT filing requirements for the small business regime. The guidance specifies that returns must be filed electronically via the online portal and due by the 25th of the month following the tax period in which VAT obligations arose or services were supplied in another EU member state. It also confirms that small business regime taxpayers in other EU member states must comply with the same electronic filing requirement.
Chile's tax authority issued Letter No. 24 on Jan. 7 clarifying that VAT payers receiving taxable services from nonresident providers must issue purchase invoices and pay VAT. The letter also requires retroactive invoicing if invoices are not issued in the same tax period as the remuneration. These guidance rules affect Chilean businesses dealing with foreign service providers.
On 14 January 2026 the Italian Revenue Agency issued Letter No. 4/2026 clarifying that an artistic foundry’s activity is a provision of services, not artwork sales. Consequently the 5 % reduced VAT rate does not apply because the foundry is not the author or rights holder of the artworks it produces. The foundry must therefore charge the standard VAT rate on its services.
Mexico’s tax authority, SAT, has issued Rule 2.9.21 under RMF 2026, mandating digital platforms to provide real‑time, permanent online access to transaction records. The rule requires next‑day data availability, a five‑year searchable archive, and a formal request by April 30 2026, with detailed data obligations for both service providers and intermediary platforms.
The VAT Refunds Manual is an HMRC internal guidance document outlining procedures for traders to claim VAT refunds. It covers eligibility, claim requirements, time limits, verification, handling of abusive or unjust enrichment claims, end‑customer refund claims, refusal procedures, appeals, and penalties.
The Czech Tax Agency clarified input VAT deduction rules for acquisitions of long‑term assets effective 1 January 2025. The guidance outlines procedures for partial deductions, incorporates the EU cross‑border regime for small enterprises, and sets a deadline for claiming deductions by the end of the second calendar year after the relevant year.